Schmidt v. Ward County Social Services Board

Summary

The North Dakota Supreme Court affirmed the denial of Medicaid and food stamp benefits to Dennis M. Schmidt’s household because funds held in a conservatorship for his minor son were available assets exceeding the applicable eligibility limits. The court held that the conservatorship was a legal device similar to a trust and that the possibility of petitioning the appointing court for distributions did not make the funds inaccessible. The court also affirmed the conclusion that the funds counted toward the household’s Medicaid and food stamp resource limits.

Holdings

1. A conservatorship established with the minor's assets is a legal device similar to a trust within the meaning of the laws governing Medicaid eligibility.
2. The conservatorship funds were actually available to Bo and therefore had to be counted in determining the household's Medicaid eligibility; because they exceeded the $6,000 asset limit for a two-person Medicaid unit, the household was ineligible.
3. The conservatorship funds were available resources that had to be counted toward the household's food stamp resource limit; because the household exceeded the $2,000 limit, the household was ineligible for food stamps.

Questions Presented

1. Whether the conservatorship holding Bo's insurance proceeds was a legal device similar to a trust and whether its funds were actually available assets for determining the household's Medicaid eligibility.
2. Whether the conservatorship funds were accessible resources that had to be counted toward the household's food stamp resource limit.
3. Whether the Department's factual determinations and benefit-termination decisions were supported by the evidence and complied with applicable law.

Disposition

affirmed